Gay pornography is the representation of sexual activity between males. Its primary goal is sexual arousal in its audience. Softcore gay pornography also exists; which at one time constituted the genre, and may be produced as beefcake pornography directed toward heterosexual female, homosexual male and bisexual audiences of any gender. Homoerotic art and artifacts have a long history, reaching back to Greek antiquity. Every medium has been used to represent sexual acts between men. In contemporary mass media, this is mostly shared through home videos (including DVDs), cable broadcast and emerging video on demand and wireless markets, as well as online picture sites and gay pulp fiction. Homoeroticism has been present in photography and film since their invention. During much of that time, any sexual depiction had to remain underground because of obscenity laws. In particular, gay material might constitute evidence of an illegal act under sodomy laws in many jurisdictions. This is no longer the case in the United States, since such laws were ruled unconstitutional by the Supreme Court in 2003 in Lawrence v. Texas. Hardcore pornographic motion pictures (stag films, as they were called prior to their legalization in 1970) were produced relatively early in the history of film. The first known pornographic film appears to have been made in Europe in 1908. The earliest known film to depict hardcore gay (and bisexual) sexual activity was the French film Le ménage moderne du Madame Butterfly, produced and released in 1920. Most historians consider the first American stag film to be A Free Ride, produced and released in 1915. In the United States, hardcore gay sexual activity did not make it onto film until 1929's The Surprise of a Knight. Other American examples include A Stiff Game from the early 1930s, which features interracial homosexual acts as part of its plot, and Three Comrades (1950s), which features exclusively homosexual activity.